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Summary of FCC E911 Phase II Reconsideration Proceeding Multi-Party Meeting
June 29, 2000
Tom Sugrue, Chief, Wireless Telecommunications Bureau, advised attendees that FCC
staff had requested this meeting with parties in order to discuss differing views as to what
needs to be done to facilitate wireless carriers' implementation of E911 automatic location
identification (ALI) technologies that comply with the FCC's accuracy and reliability
requirements. The FCC's goal is to have accurate, reliable, and ubiquitous E911 service,
but the question today is how to get there.
FCC staff proceeded to pose the following questions to parties in attendance.
1. What ALI solutions are available, or likely to be available, network-based,
handset-based, or hybrid, within the next few years, i.e., by 2005, for the various
wireless interfaces?
Verizon Wireless
Verizon Wireless (now comprising the former AirTouch, Bell Atlantic Mobile, GTE
Wireless, and PrimeCo) indicated that it has been concentrating primarily on testing
network-based solutions for the CDMA air-interface, and to a lesser degree, for AMPs.
Verizon stated that it had tested with True Position and U.S. Wireless, but has done little
independent verification of test results reported by location technology vendors. Verizon
has primarily been testing in suburban areas. It has planned an urban and limited
suburban network-based test in Manhattan that should conclude before the end of
September, but has not tested in extremely rural areas. Verizon indicated that it has not
pursued testing of handset-based or hybrid technologies.
Sprint PCS
Sprint PCS indicated that it has been exploring network-based solutions for CDMA since
the first quarter of 1997, working with Radix, the only developer that was developing a
network-based solution. In Spring 2000, Sprint completed a lab test with Radix, which
showed that the technology works well in ideal situations (suburban), but does not work in
certain other situations. Sprint has not done real world testing of this technology. Sprint
stated that it does not consider this network solution a good fit and that it would be
challenged to deploy the technology in its system. One of the difficulties would be lack of
physical room in Sprint base stations, because base stations have been shrinking. Sprint
has tested Lucent's server-assisted GPS solution in Tampa but no data is available yet.
Sprint has done some limited testing with Lucent's hybrid forward link triangulation
(FLT) technology, which has shown some good and bad results. The technology shows
some promise and may improve with alternative engineering, but currently does not meet
the accuracy and reliability requirements.
VoiceStream Wireless
VoiceStream Wireless indicated that it has performed some time-of-arrival (TOA) trials
for GSM at several sites. Although it shows some promise for meeting the mandate
VoiceStream is no longer pursuing that solution, because there is currently no TOA
equipment available from major vendors for GSM. VoiceStream expressed concern about
the location technologies causing a reduction in spectrum efficiency for GSM networks.
Also, Voice Stream stated that it does not appear that GPS handsets for GSM will be
available in time. Enhanced Observed Time Difference (E-OTD) appears to be the best
solution, and it may be deployable by the deadline. VoiceStream is currently participating
in a trial with BellSouth and other GSM operators and vendors, and results will be
forthcoming. VoiceStream has not considered a GPS solution.
Ericsson
Ericsson indicated that with respect to GSM systems, it is currently commercially
supplying cell ID and timing advance location technology in Europe (500-meter accuracy
or less), and has investigated TOA, server-assisted GPS, and E-OTD. Ericsson is pursuing
an enhancement to the cell ID and timing advance technology that moves closer to the
required accuracy and reliability, but this technology currently does not meet the
requirements. Ericsson stated that it has also been looking into E-OTD. Ericsson believes
E-OTD will probably be available around the deadlines set forth, but contends that this
technology will not meet the handset accuracy and reliability mandates (50 meters 67% of
the time/150 meters 95% of the time for handset-based systems). Ericsson has performed
server-assisted GPS lab trials for GSM and some limited field use. The results so far have
been good, but there is little enthusiasm from carriers due to added complexities.
With regard to TDMA, use of cell ID and timing advance raises bandwidth issues and
yielded poorer results than use of such technology with GSM. Ericsson's tests of E-OTD
with TDMA systems yielded results that did not meet the accuracy requirements.
Ericsson stated that E-OTD would also require TDMA network hardware and software
additions that can not be accomplished within the required time frame. Ericsson indicated
that using E-OTD with TDMA systems is more difficult, and achieves lower accuracy
levels, than use of E-OTD with GSM, because of differences in bandwidth and processing
times between the air interfaces. Ericsson expressed the opinion that use of E-OTD with
TDMA will be better than Phase I, but will not meet Phase II requirements.
Ericsson stated that, for TDMA and GSM, server-assisted GPS accuracy meets the
requirements but delivering handsets on schedule would be highly problematic. Also,
Ericsson is not pursuing an in-house network solution, and instead is assisting third parties
with the development of these solutions for CDMA and TDMA interfaces. Ericsson is
concerned, however, about having to vouch for the efficacy and reliability of any network
solution. Ericsson is using Qualcomm GPS chipsets for CDMA and has not done any
work on a hybrid solution for CDMA. The accuracy of the cell ID and timing advance
solution, when used with TDMA, is 200-500 meters, depending on the environment, and
will not get much better. Of the various air interfaces, Ericsson believes that, in the long
run, GSM will have the most options among location technologies.
Qualcomm
Qualcomm indicated that it has two separate location technology applications: SnapTrack,
which licenses assisted GPS location technology, and QCT, which manufactures CDMA
chipsets. Qualcomm indicated that several major manufacturers are SnapTrack licensees,
and stated that there is no air interface at a disadvantage with its core technology.
Qualcomm asserted that one manufacturer plans to develop a base-band device
incorporating SnapTrack assisted-GPS technology, which will enable manufacturers to
produce handsets by 3Q 2001.
Qualcomm plans to provide sample GPS chipsets for base-band and RF (cellular and
GPS), along with accompanying reference designs, by September 2000. Qualcomm stated
that some of its equipment manufacturer customers should be able to produce handsets
within 6 months after that. Qualcomm has completed extensive testing for combined
handset solutions. A handset sample is needed to test software in the field and production
can begin 6 months after sample is tested. Qualcomm stated that it has overcome
interference problems associated with the cellular and GPS frequencies to develop a
unified antenna that is used in prototype handsets. Some loss of reception was budgeted
into the design for this antenna. Qualcomm asserted that for GPS hardware, battery use is
insignificant and extra memory will be integrated into the chipset, but less memory is
needed with time-domain processing.
Ericsson commented that integrating the chipsets into a handset would be expensive and
will take longer than 6 months. Ericsson stated that the time frame to move from a chipset
to a viable handset is more like 9 to 18 months. Ericsson noted that Qualcomm does not
supply numerous cell phone components, such as control software, documentation, PC
board, user interface, buzzer and keypad, and is not involved in customer support and type
acceptance activities. Qualcomm replied that Ericsson has successfully used Qualcomm's
chips in the past, and that Qualcomm would provide base band, MSM, IF, and RF chips
and software design documentation; moving to a new model is a simple migration from an
older model.
Sprint agreed that the additional features, other than GPS, desired by customers would add
time to the design and production of new models. Sprint also inquired whether the
Qualcomm chipset scheduled for sampling in September will incorporate 1X RTD
capability. Qualcomm responded that a chipset incorporating 1X RTD capability, the MX
5100, would be sampled in December 2000.
Qualcomm stated that, after extensive testing of assisted GPS in favorable and unfavorable
environments (urban canyons, high-rises, and rural areas) for AMPS, PDC, GSM, iDEN,
and CDMA (AMPS and CDMA results filed with the FCC), it found there are certain
environments where assisted GPS will fail (e.g., in a building with a metal roof and metal
windows). Results of the assisted-GPS test demonstrated suburban highway accuracy to
be 5-30 meters; urban high-rise accuracy was 30-90 meters. With network enhancements,
assisted GPS would work better in buildings.
Qualcomm tested the AFLT technology with Sprint and concluded that it would be
difficult to meet the accuracy mandates using AFLT. Qualcomm also expressed the
opinion that the E-OTD hybrid solution, which is similar to AFLT, would not meet the
accuracy mandates.
Ericsson stated that it might be able to provide E-OTD handsets for GSM systems towards
the end of 2001, but can not promise.
VoiceStream anticipated that E-OTD handsets would be available to meet the requirement
for 50% new activation by October 1, 2001, but is unsure about availability of network
infrastructure - possibly by 3Q or 4Q 2001. VoiceStream also indicated that standardized
interfaces to PSAPs have not yet been finalized. VoiceStream further expressed the
opinion that cell i.d. and timing advance may be slightly less accurate than the 200-500
meters estimated by Ericsson.
2. Will the PSAPs be ready?
APCO indicated that there has been a lack of information in the PSAP community, but
that is changing and there is significant interest in making Phase II happen. As for Phase
I, there were in excess of 3,000 requests from PSAPs (now about 60%). Three to four
hundred PSAP personnel have attended APCO's recent seminar series, suggesting there is
interest in Phase II. For example, in Texas, there was almost 0% Phase I implementation
one year ago, and today there is almost 100% implementation. There has been substantial
progress after the cost recovery rule clarification, but there is need to break the logjam for
the handset approach to Phase II since carriers are blaming manufacturers for not
producing and manufacturers are blaming carriers for not ordering. PSAPs are more
interested in Phase II than Phase I and want, in some cases, to go directly to Phase II, but
do not understand that Phase I is a necessary component of Phase II and will provide the
fallback when a call cannot be located by Phase II technology. Costs to PSAPs for
equipment necessary for Phase II are not that large.
Sprint reported that it has received requests for Phase II and has been proactive because
there is a lot more interest than for Phase I. Carriers expressed concern that most costs for
Phase II implementation are on carriers' side, not the PSAPs' side. VoiceStream
estimated that carrier expenses for implementing Phase II would be 10 to 100 times higher
than implementing Phase I.
4. What are other factors affecting the utility and efficiency of these solutions and the
decisions that carriers will make?
Verizon stated that it is in the process of introducing tri-mode (PCS/ CDMA 800/ analog)
handsets. Handset replacement amongst its existing customer base would be problematic
and very costly, and thus requires a network solution today and probably a handset
solution tomorrow. There are also concerns with first generation products (CDMA in
particular). Improvements in accuracy may have to wait until second and third generation
products.
Sprint indicated that there are serious operational deployment issues for handset
implementation that will involve considerable negotiations between handset and network
people, as well as a substantial testing phase to resolve glitches. In some cases, there will
be a more expensive handset for a service that is not available everywhere. Sprint is also
concerned about the large carrier investment with possibly little or no return on the
investment.
APCO is concerned with customer unawareness about the safety constraints on wireless
E911, because many wireless callers assume the PSAP knows where they are located, as is
the case with calls from wireline phones.
Sprint stated there will be a financial backlash on carriers if someone can not be located.
Also, other new services are being deployed, e.g., 1X capability which provides data rates
of 144 kbps and doubling of voice capacity. Sprint does not want to market GPS handsets
without 1X capability.
APCO reiterated its concern that the original FCC directive of 1996 has not spurred
satisfactory movement on the part of carriers. APCO also expressed concern that every
day of delay means more non-compliant phones will be sold. Sprint responded that it is
not suggesting further delay, but would like to deploy technology that can provide location
accuracy to the several hundred meters level, such as AFLT, simultaneous with the
introduction of GPS handsets.
APCO expressed concern that implementing AFLT would impose huge infrastructure
costs, and will not provide the requisite accuracy levels. Sprint stated that AFLT and GPS
standards are the same, so an AFLT-capable network will support GPS. Sprint further
clarified that assisted GPS is its preferred long-term approach, but that it would like to
have multiple mechanisms to be comfortable with E911, such as GPS with AFLT fallback.
Qualcomm noted that GPS could be deployed without Location Measuring Units (LMUs)
that are needed for E-OTD. A GPS chip will be available by September 2000, and a
chipset with 1X and GPS by December 2000. AFLT is hybrid that can be employed with
GPS. If a handset can see less than three satellites, add one base station; less than two
satellites, add two base stations.
5. Are you comfortable it works?
Sprint replied that the assisted GPS technology works well based on the trials they have
participated in, but the problem is getting GPS out in the market. Sprint also expressed
concern that assisted GPS has never been deployed or tested on a broad commercial scale
and therefore, it is difficult to say definitively how well it would work in a real-life
deployment.
VoiceStream asserted that with E-OTD it could hit 100-meter accuracy. Qualcomm
challenged this assertion, expressing the opinion that under ideal circumstances E-OTD
with GSM systems could only reach an accuracy level of 150-200 meters.
Ericsson stated that given availability representations, carriers are reluctant to place orders
and manufacturers can not produce until orders are placed. It is the chicken and egg
phenomenon.
Qualcomm stated that it thinks that AFLT does not meet the 100-meter accuracy standard.
Its testing has yielded poor results, and Qualcomm believes it is unlikely it will meet the
standard. Also, Qualcomm stated that E-OTD raises bandwidth concerns for GSM that
make it a problematic approach for ever achieving reasonable accuracy levels.
VoiceStream challenged Qualcomm's characterization of GSM technology and stated that
it is running a large E-OTD in Texas, and, so far, 40% of the results are within 50 meters.
Testing will continue over the next several months. Also, VoiceStream indicated that
there are techniques in E-OTD that can improve the accuracy with GSM.
6. Why not go ahead and order handsets from suppliers?
Verizon stated that legacy equipment is a huge problem and has a strong preference for a
network solution. Sprint favors assisted GPS for CDMA, but recognizes the competitive
pressures that exist for manufacturers and the chicken and egg problem. Sprint has asked
manufacturers to develop assisted-GPS technology, but manufacturers will not do so on
speculation. Sprint stated that the timing has not been right to place an order.
7. Conclusions
Qualcomm stated that its GPS technology will be available in the near future and meets
the mandated accuracy and reliability. Its technology is widely licensed and will be
available for all interfaces. Qualcomm is skeptical of hybrid solutions.
VoiceStream stated that it is committed to its E-OTD technology, and there will not be
any other technology available for GSM in the allowed time frame. Though there are cost
implications and commercial service implications, the first option is to use E-OTD.
Sprint stated that it could not meet performance, cost, and schedule criteria all at once.
Instead, Sprint will have to use multiple technologies.
Ericsson expressed concern about commercializing solutions and the ability to provide
infrastructure. There is some uncertainty whether the technologies can meet the
performance requirements. The best approach is not to pursue multiple options but to
direct investment towards fewer options.
APCO stated that delays are bad for public safety. Everyone has to be realistic, but lives
are at stake. The technology exists, but it is needed on the street.
Verizon stated that its trying hard to meet the mandate, but more testing needs to be done.
If there are a large number of PSAP requests, Verizon could have difficulty meeting the
deployment schedule. Verizon indicates that it will do its best but is not sure if a single
approach will work for the whole country.
FCC E911 Multi-Party Meeting
June 29,2000
Name: Company/Organization:
Joe Hanna APCO
Bob Gurss APCO
Barbara Baffer Ericsson
Scott Bloebaum Ericsson
William Gast Ericsson
Bob Bromery FCC/OET
Bob Eckert FCC/OET
Dale Hatfield FCC/OET
Alexander Dobrev FCC/WTB
Patrick Forster FCC/WTB
Dan Grosh FCC/WTB
Gil Hopenstand FCC/WTB
Jennifer Kolen FCC/WTB
Bill Lane FCC/WTB
Marty Liebman FCC/WTB
Ron Netro FCC/WTB
Jim Schlichting FCC/WTB
Blaise Scinto FCC/WTB
Tom Stanley FCC/WTB
Tom Sugrue FCC/WTB
Jonas Neihardt QUALCOMM INC.
Sanjay Jha QUALCOMM INC.
Saed Younis QUALCOMM INC.
Ellen Kirk Snap Track
Jonathan Chambers Sprint PCS
Brian Finnerty Sprint PCS
Terry Rayburn Sprint PCS
Bruce Ciotta Verizon Wireless
Luisa Lancetti Verizon Wireless (Wilkinson Barker Knauer )
Bob Calaff Voice Stream
Beth Frasco Voice Stream
Brian O'Connor Voice Stream
Robert Rowe Voice Stream
In subsequent conversation with WTB Policy Division staff, Qualcomm amended this statement to the
effect that while samples of a chipset incorporating 1X RTD capability will be available in December 2000,
this chipset will not incorporate server-assisted GPS capability. Qualcomm indicated that samples of the
MX 5100 chipset, which incorporates both 1X RTD and assisted-GPS capability, will be available in March
2001. See letter from Veronica M. Ahern, Nixon Peabody LLP, to Magalie R. Salas, Secretary, FCC dated
July 7, 2000, at 2.
See note 1 above.
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